E

esco

Well Known Member
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Can anyone cite the no-kidding requirement for fuel filler placards or labels?

I'm about to re-label mine, but a search of this site, EAA, and others, to include the CFR, and a detailed search of Title 14, doesn't show a requirement that applies to experimental aircraft.

As you might guess, I found much opinion, some conjecture about the history of color coding fuel filler caps(!), some "my DAR won't sign off" and some "my A&P sez" ... but not a single citable requirement.

thx
 
It is required -

Identifying fuel and ensuring the correct fuel is delivered
into storage tanks, fuel trucks, and aircraft fuel tanks is a
process aided by labeling. Decals and markings using the
same colors as the AVGAS colors are used. Delivery trucks
and hoses are marked as are aircraft tank fuel caps and fill
areas. Jet fuel fill hose nozzles are sized too large to fit into
an AVGAS tank fill opening. Figure 14-9 shows examples
of color-coded fuel labeling.

Source
Title 14 of the
Code of Federal Regulations (14 CFR) (AIRCRAFT FUEL SYSTEMS) guidelines.

The directive applies to storage tanks, trucks, hoses and aircraft, it does not exempt "experimental" aircraft.
 
David-aviator said:
It is required -

Identifying fuel and ensuring the correct fuel is delivered
into storage tanks, fuel trucks, and aircraft fuel tanks is a
process aided by labeling. Decals and markings using the
same colors as the AVGAS colors are used. Delivery trucks
and hoses are marked as are aircraft tank fuel caps and fill
areas. Jet fuel fill hose nozzles are sized too large to fit into
an AVGAS tank fill opening. Figure 14-9 shows examples
of color-coded fuel labeling.

Source
Title 14 of the
Code of Federal Regulations (14 CFR) (AIRCRAFT FUEL SYSTEMS) guidelines.

The directive applies to storage tanks, trucks, hoses and aircraft, it does not exempt "experimental" aircraft.
Click to expand...

But what section? That part makes a difference. The material you linked to is not the regulation; it appears to be a chapter from the Aviation Maintenance Technician airframe handbook.

Part 23 contains a requirement for marking the filler cap, but homebuilts are not required to comply with Part 23.


Edit: the actual regulations can be viewed here: http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title14/14tab_02.tpl

23.1557 C.1.(i) is the requirement, but again, Part 23 compliance is not required for homebuilts.
 
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Placards

This is the FAA's latest gig.... No fuel placard and you are busted.
Need Min. fuel grade and Qty.
 
Again, that is not a regulation. It is a handbook. It appears to be restating the certification requirements in plain English ("These paragraphs from 14 CFR part 23, Normal, Utility, Acrobatic, and Commuter Category Airplanes, are
summarized below. Airworthiness standards specified for air carrier and helicopter certification are similar.") It does not constitute a legal requirement for such marking in order to get a certificate of airworthiness, nor to operate the aircraft.

My searching shows fuel placarding is only mentioned in Parts 23, 25, 27, and 29. None of these apply to homebuilts.
 
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confusing?

..yes, especially the line on 14-2 that says...
" each fuel system must be arranged so that no fuel pump can draw fuel from more than one fuel tank at a time......"

so, all these thousands of aircraft with a 'both' setting on the selector are in violation???? Illegal?.....Immediately to be grounded?:eek:

I labeled mine with 100LL, then thought I'd be in violation if I ran some mogas, so added. " Minimum 80 octane - cap. 18 USG - 68 Litres" just to cover all the bases.

funny how nowhere does it say 'gasoline', as I don't want to say only Avgas, but what DOES one put on there???

sorry, not meaning to drift from the question;
where the heck are the regs?
 
I agree with the previous post, there is no regulation pertaining to experimental aircraft requiring fuel qty or type markings. It it highly advisable however and since the experimental certificate is issued with a lot of policy behind it, I could see a DAR wanting it to issue the certificate.
 
flyboy1963 said:
..yes, especially the line on 14-2 that says...
" each fuel system must be arranged so that no fuel pump can draw fuel from more than one fuel tank at a time......"
[/B]
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.......... "so, all these thousands of aircraft with a 'both' setting on the selector are in violation???? Illegal?.....Immediately to be grounded?"

If there is a fuel pump on a high wing, it is fed with a small amount of pressure. One tank will usually run out first, and the other will continue to feed fuel to the pump because it is heaver that air.

Low wing aircraft fuel pumps usually have to suck the fuel to the pump. If more than one tank is connected to the pump at a time, when it runs out of fuel, the pump will not pull gas from the other tank. It will pump air from the empty tank and the remaining fuel in the other tank becomes useless.

I doubt if you will find a "both" setting on a certified aircraft that does not have gravity flow.
 
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gasman said:
.......... "so, all these thousands of aircraft with a 'both' setting on the selector are in violation???? Illegal?.....Immediately to be grounded?"

If there is a fuel pump on a high wing, it is fed with a small amount of pressure. One tank will usually run out first, and the other will continue to feed fuel to the pump because it is heaver that air.
snip
.
Click to expand...

The question there wasn't whether it works, but whether it meets the letter of the regulation.
 
rv7charlie said:
The question there wasn't whether it works, but whether it meets the letter of the regulation.
Click to expand...

The operative words are "fuel pump". A gravity-fed carbureted Cessna, for example, has no fuel pump, so that rule doesn't apply.

If there is a fuel pump and a "both" position, the rule may have been different when the aircraft was certified. Are you aware of any aircraft so equipped?
 
Thx for confirmation

Perry, Bob, David, Dan:

Appreciate the input, confirming what I thought: highly advisable, but no discernible requirement found... so far.
 
Some high wing Cessnas are injected and would have fuel pump(s) ... don't know if those have a "both" setting?
 
file not found! :-(

sorry, my post wasn't very helpful, not to open different can 'o worms with the 'both' setting.

I also searched and can find only Part 23, with what sure looks like a 'regulation' complete with the words, 'must', but devoid of reference to amateur-built or experimental of course.

http://www.risingup.com/fars/info/part23-1557-FAR.shtml

Part 23 > Sec. 23.1557 - Miscellaneous markings and placards

sounds like this is the classic case of " Please Mr. DAR, can you show me the section requiring this placard?"

rather than him saying " show me the section excluding it!" which seems to be nigh impossible to locate.
 
flyboy1963 said:
sounds like this is the classic case of " Please Mr. DAR, can you show me the section requiring this placard?"

rather than him saying " show me the section excluding it!" which seems to be nigh impossible to locate.
Click to expand...

So you're walking down the street and turn the corner... and a cop stops you.

Cop: "I'm citing you for failure to signal your turn."

You: "Wha?? I don't have to use signals when I'm walking."

Cop: "The law says you do. See, right here in the traffic statutes. All drivers must signal turns 100 feet before the intersection."

You: "But I'm not driving! I'm walking! See, it says all drivers."

Cop: "Show me the section of the traffic laws that excludes people walking."

You: (scratches head in amazement...)
 
Is this exercise simply a legal discussion or is there a valid reason to not label an aircraft fuel tank?

If it is a legal exercise, it is not a good subject, the tanks should be labeled. It is dumb not to.

It would be interesting if the aircraft were serviced with inappropriate fuel, crashed on account of it and an investigation determined the tanks had been labeled and then deliberately not labeled. An insurance company would use that loop hole in a minute to not pay the claim.

Install the labels, it is a good practice whether required or not.
 
David:

As noted in my original post, I'm about to re-label my tanks.

I did not ask for opinions on whether I should or not (see my "highly advisable" response); instead, I'm looking for the requirement, which has not turned up on this forum.
 
Placards

If your placard next to the fuel cap has "FUEL" Qty_____ & Min Octane______ all bases are covered and any inspector should be satisfied. I can't reference anywhere in the Far's where this is ironclad but production aircraft are usually labeled like this when manufactured.


Don Broussard A&P, IA, ATP

RV 9 Rebuild in Progress
 
A DAR/FAA Inspector can deny an airworthiness certificate for anything he considers unsafe regardless of FARs. If you disagree with his "findings", you are free to find another inspector. But be aware, the new inspector will be familiar with the reason for your denial as it is immediately broadcast to all inspectors.

Example: There is no FAR that says you must use AN bolts. But I don't know of any inspector that will sign off an airplane put together with aluminum screws.

Personally I consider unmarked fuel tank fillers to be an unsafe condition.
If you disagree with this, I suggest that you talk with your inspector before submitting your 8130-6.
 
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Mel said:
A DAR/FAA Inspector can deny an airworthiness certificate for anything he considers unsafe regardless of FARs. If you disagree with his "findings", you are free to find another inspector. But be aware, the new inspector will be familiar with the reason for your denial as it is immediately broadcast to all inspectors.

Example: There is no FAR that says you must use AN bolts. But I don't know of any inspector that will sign off an airplane put together with aluminum screws.

Personally I consider unmarked fuel tank fillers to be an unsafe condition.
If you disagree with this, I suggest that you talk with your inspector before submitting your 8130-6.
Click to expand...

And although this system works extremely well *most of the time*, it has the potential for some serious abuse, as we've seen occasionally here (such as creating requirements which don't exist, insisting on full tear-down inspections of engines, requiring practices in direct contradiction to manufacturer's written instructions, etc.).

Pray tell, how does such a system prevent such arbitrariness and, frankly, ridiculous, practices by DARs while still allowing them the freedom to help builders ensure their aircraft are safe? No system is perfect, after all...

(BTW, as I've said before, my DAR was outstanding...thorough, precise, full of knowledge, no BS made-up "regulations", courteous and professional...so I have no inherent beef against DARs or FAA/FSDO inspectors...I'm just asking :) ).
 
Mel said:
A DAR/FAA Inspector can deny an airworthiness certificate for anything he considers unsafe regardless of FARs. If you disagree with his "findings", you are free to find another inspector. But be aware, the new inspector will be familiar with the reason for your denial as it is immediately broadcast to all inspectors.

Example: There is no FAR that says you must use AN bolts. But I don't know of any inspector that will sign off an airplane put together with aluminum screws.

Personally I consider unmarked fuel tank fillers to be an unsafe condition.
If you disagree with this, I suggest that you talk with your inspector before submitting your 8130-6.
Click to expand...

Before I retired, I also required the fuel tank filler labels. I also thought without them was an unsafe condition. Too many accidents for aircraft getting fueled with the incorrect fuel.

Old OpLims required:
This aircraft must contain the placards, markings, etc., as required by 14 CFR ? 91.9. In addition, the placards and markings must be inspected for legibility and clarity, and the associated systems inspected for easy access and operation, to ensure they function as intended by the amateur builder/owner during each condition inspection. (13)

91.9 Civil aircraft flight manual, marking, and placard requirements.
91.9 (a) ...no person may operate a civil aircraft without complying with the operating limitations specified in the approved... ...markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry.
 
RV7A Flyer said:
Pray tell, how does such a system prevent such arbitrariness and, frankly, ridiculous, practices by DARs while still allowing them the freedom to help builders ensure their aircraft are safe?
Click to expand...

The same way it does in any other free market... Word will spread fast ( in forums such as this, etc.) and in a very short time that DAR would no longer have much work to do.
 
esco said:
David:

As noted in my original post, I'm about to re-label my tanks.

I did not ask for opinions on whether I should or not (see my "highly advisable" response); instead, I'm looking for the requirement, which has not turned up on this forum.
Click to expand...

I apologize. The tone of the original post (as I read it) was, if it is not required, why do it? Why else pose the question?

Perhaps the word "requirement" should be defined in context with building, certifying and flying an experimental airplane.

In reality, requirement here means you will comply or you won't be flying an experimental airplane.

Comply with what?

AC 20-27G as a starter.

An Advisory Circular does not have the teeth of regulation, it can not be enforced but if one does not comply with this particular AC concerning what we do, the experimental airplane will not be certified. Hence, compliance with AC 20-27G is a requirement, not a legal one, but it is a requirement.

I believe the FAA does this deliberately to regulate what they want to regulate without going through the tedious process of writing the intent of an AC into regulation. And it is all done under the mantra of flight safety. I do not disagree with this. Its just a back door way to get the job done.

My first airplane, a Long EZ, was certified long before there was "guidance" in the form of an AC concerning this matter. Things were not as tight as today and the accident rate reflected it. The effort bringing us to where we are today, while contentious to some, has made experimental flying safer. I do not believe the FAA is intent on getting rid of what we do, but they do wish to control it and the accident rate. EAA has been complaisant in this effort.

The question as to whether a particular action is legally "required" is moot. One can argue a point all day and be correct, but in the end you will not win. :)
 
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rvbuilder2002 said:
The same way it does in any other free market... Word will spread fast ( in forums such as this, etc.) and in a very short time that DAR would no longer have much work to do.
Click to expand...

Except it's not much of a free market in many places (shortage of DARs, maybe none, leaving only FSDO inspectors to draw upon), and how many times have we seen weird "requirements" from inspectors and DARs which people comply with (usually to undo later, of course).

And in all of the discussions of outrageous requirements being ginned up out of thin air on these forums, how many times have you seen said inspector's name published? I can't recall a single instance.

I'm all for inspectors bringing to bear their expertise to help builders create safer aircraft, but the open-ended "anything they want to insist on" is not a good approach.

Examples:
Paint your fuel caps red
Don't do what Hartzell says on safety wiring the prop, do what I want done
Your legal "Experimental" placard isn't enough...put more on in other places
Change all the nylocks that Lycoming installed on your new engine, because I don't like nylocks...use steel lock nuts instead
I know the rule says "magnetic direction indicator", but I say you have to *also* have a wet compass
ETA a few more that a quick search turns up:
Run your new engine on the ground for at least an hour
Put labels on your static ports
etc.

or I won't give you your airworthiness certificate. Why? Because I said so, and I can make you do anything I want if you want to get it.

I would prefer a system where compliance with regulations is verified, construction iaw best practices is evaluated, and anything else is a *recommendation*, not a requirement for issuance.
 
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RV7A Flyer said:
And in all of the discussions of outrageous requirements being ginned up out of thin air on these forums, how many times have you seen said inspector's name published?
Click to expand...

True, but word does spread in the local area where said DAR works... I have seen it happen.
 
Thanks y'all

esco said:
Perry, Bob, David, Dan:

Appreciate the input, confirming what I thought: highly advisable, but no discernible requirement found... so far.
Click to expand...

And equally sincere thanks to Gary, Scott, and Mel and anyone else that weighed in.

My intent was not to rekindle an old argument, start a new one, or poke any bears; rather, I wanted to know the source of the requirement. As of now, the answer appears to be Custom, based on hard-won experience, and not Regulation. I consider my question answered.

I'll start shopping for Part-23 compliant labels. Vince Frazier, you out there?
 
"I'm all for inspectors bringing to bear their expertise to help builders create safer aircraft, but the open-ended "anything they want to insist on" is not a good approach."

Indeed. DARs do not have regulatory powers I presume (I'm Canadian), so they certainly cannot make stuff up as they go along.

The regs they do follow may however give them great latitude (such as "make sure the airplane is built in compliance with accepted aerospace techniques", etc.). Maybe too much latitude?

Here in Canada the inspectors are "delegated" by Transport Canada. They follow the regs (or at least should), because they have no regulatory powers. They should be able at any point to say "I'm making you do this because of reg X.Y.Z". May the reg they point to is really broad, but if it at least "fits" ...

The concern is when there is a specific rule written about something, and they decide to go above and beyond it ...
 
DARs do not have regulatory powers I presume (I'm Canadian), so they certainly cannot make stuff up as they go along.
Click to expand...

I just gave you a list of things that *have* been made up by inspectors! Those are all from reports/posts on this forum!
 
A word of caution.....

If you are having your fuel caps engraved I wouldn't put "LL" on them. Only the qty and minimum grade is needed. Minimum grade being octane!. You can put "100 Octane", "92 Octane", or whatever. Lead content is not needed. Someday 100LL will go away. Then what will you use?
 
Mel said:
If you are having your fuel caps engraved I wouldn't put "LL" on them. Only the qty and minimum grade is needed. Minimum grade being octane!. You can put "100 Octane", "92 Octane", or whatever. Lead content is not needed. Someday 100LL will go away. Then what will you use?
Click to expand...

Mel, I respectfully disagree. Is the point to obey an arbitrary rule, or is it to try to prevent a re-fueling disaster from some lineboy who has no idea what octane means? I say, the more explicit information, the better. New gas caps are cheap compared to a trashed engine.
 
BobTurner said:
Mel, I respectfully disagree. Is the point to obey an arbitrary rule, or is it to try to prevent a re-fueling disaster from some lineboy who has no idea what octane means? I say, the more explicit information, the better. New gas caps are cheap compared to a trashed engine.
Click to expand...

I NEVER let a lineman fuel my plane without me standing next to him.

I'm much more concerned about him turning loose of the nozzle and damaging the cap flange (and top of the tank) than having Jet-A put in a little piston plane.
 
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Sam Buchanan said:
I NEVER let a lineman fuel my plane without me standing next to him.

I'm much more concerned about him turning loose of the nozzle and damaging the cap flange (and top of the tank) than having Jet-A put in a little piston plane.
Click to expand...

Me neither -so far. But some day I might forget to tell them to wait for me. I'm also afraid they don't know the 'push down to release' operation of the gas caps.
 
No. My point was that when 100LL goes away, you will have to get new fuel caps because you can no longer fuel your aircraft with 100LL.

There is no problem with having "100LL" on them now, but later it can become a problem.
 
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